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Home My WebLink About09-4667Maieyiana L. Luciani, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No.09- /(¢(/7 Thomas J. Luciani, Defendant IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Maieyiana L. Luciani, Plaintiff vi. Thomas J. Luciani, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09- 1/6 (,7 el';o?,( 7Z IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Maieyiana L. Luciani , who currently resides at 1 West Penn Street, Apartment 401, Cumberland County, Pennsylvania, since on or around 2004. 2. Defendant is Thomas J. Luciani, who currently resides at, 1 West Penn Street, Apartment 401, Cumberland County, Pennsylvania, since on or around 2004. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on, June 15, 2006 in Cumberland County. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken and the parties were separated on May of 2008. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. By: Maieyiana L. Luciani, pro se VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: ( r Q D V ,2? q P/ Maieyiana L. Luciani, Plaintiff Assisted by: Vincent M. Monfredo, Esquire Rominger Law Office 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 . 'i L. F. p Maieyiana L.Luciani IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 09- qU117 CIVIL TERM Thomas J. Luciani Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Maieyiana L Luciani Plaintiff, to proceed in forma au eris. I, Vincent M. Monfredo, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Vincent M. Monfredo, Esquire Attorney for Plaintiff Rominger Law Office 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 f i LE LU° 7 j 1 t (i ?• 4 .J Maieyiana L. Luciani Plaintiff V. Thomas J. Luciani Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- ?qUU7 CIVIL 'TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on ??) live separate and apart for a period of two years. and continued to 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. Date )Alj l?- Plaintiff, Pro Se FLED--`- ?k M9 JI-J' 13 MAIEYIANA WRIGHT LUCIANI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. THOMAS J. LUCIANI, Defendant CIVIL ACTION LAW No. 09 - 4667 IN DIVORCE PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of THOMAS J. LUCIANI, the Defendant, in the above captioned matter. Date: ??v a 9 Adam Britcher Certified Legal Intern Meg 'esmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 3-L r try ?r ? ''s t 7